United States v. Jorn
Jorn was charged with numerous counts of assisting in the preparation of fraudulent income tax returns.Among the government's witnesses were five taxpayers whom Jorn had allegedly assisted in preparing fraudulent returns.Here, the trial judge had acted sua sponte, abruptly discharging the jury without input from either the prosecution or defense.The Court used the framework of United States v. Perez to evaluate this action, asking whether there was "manifest necessity" to declare the mistrial.Here, the Court concluded, "the trial judge here abused his discretion in discharging the jury," suggesting instead the possibility of a continuance.